Edgar Monserratt v. Tesla Inc, et al Document 29

County Court in and for Broward County, Florida
Case No. CACE19000422
Filed June 5, 2019

Notice of Production From Non-Party

BackBack to Edgar Monserratt v. Tesla Inc, et al

Tags No tags have been applied so far. Sign in to add some.

  Formatted Text Tab Overlap Raw Text Right End
Page 1 Filing # 90602002 E-Filed 06/05/2019 11:15:17 AM
IN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA
CASE NO.: CACE-19-EDGAR MONSERRATT, as_ Personal
Representative of THE ESTATE OF
EDGAR MONSERRATT MARTINEZ,
Deceased,
Plaintiff,
V.
TESLA, INC. a/k/a TESLA FLORIDA,
INC., HALSTON LOYD, JAMES BB.
RILEY, individually, JAMES B. RILEY as
the Personal Representative of THE
ESTATE OF BARRETT RILEY, Deceased,
and JR CORPORATE SERVICES GROUP
LLC, a Florida limited liability company,
Defendants.
/

NOTICE OF PRODUCTION FROM NON-PARTY
YOU ARE HEREBY NOTIFIED that after ten (10) days from the date of service of this
Notice the undersigned will apply to the Clerk of this Court for the issuance of the attached
subpoenas directed to those listed below, who are not parties, to produce the items listed at the
time and place specified in their subpoenas:
1. NBC 6 South Florida
15000 SW 27' Street
Miramar FL
2. CBS 4 Miami
8900 SW 18" Terrace
Doral FL
[INTENTIONALLY LEFT BLANK]
** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/05/2019 11:15:17 AM.**#*
Page 2 WE HEREBY CERTIFY that a true and correct copy of the foregoing has been served
via electronic mail and facsimile this 5“ day of June, 2019, to all parties on the attached list.
SCHLESINGER LAW OFFICES, P.A.
Attorneys for Plaintiffs
1212 SE Third Avenue
Fort Lauderdale, Florida
/s/ Zane Ber
Scott P. Schlesinger, Esq.
Florida Bar No.: scott@schlesingerlaw.com
Jonathan R. Gdanski, Esq.
Florida Bar No.: jonathan@schlesingerlaw.com
Zane Berg, Esq.
Florida Bar No.: zane(@schlesingerlaw.com
Page 3 SERVICE LIST

SCOTT P. SCHLESINGER, ESQ. PHILIP HARNETT CORBOY, JR., ESQ.
JONATHAN R. GDANSKI, ESQ. CORBOY & DEMETRIO, P.C.
ZANE BERG, ESQ. 33 N. Dearborn Street
SCHLESINGER LAW OFFICES, P.A. Chicago IL
1212 Southeast Third Ave Tel: (312)346-
Fort Lauderdale FL 33316 fhe@corboydemetrio.com
Tel: (954)320-9507 Co-Counsel for Plaintiff
Fax: (954)320-
scott@schelsingerlaw.com
jonathan@schlesingerlaw.com
zane@schelsingerlaw.com
priscilla@schlesingerlaw.com
Attorneys for Plaintiff, Edgar Monserratt, as Personal Representative of The Estate
of Edgar Monserratt Martinez, Deceased




ROBERT J. RUDOCK, ESQ.
WHITNEY V. CRUZ, ESQ.
BOWMAN AND BROOKE LLP
Two Alhambra Plaza, Suite
Coral Gables, FL
Tel: (305) 995-
Fax: (305) 995-
Robert.Rudock@bowmanandbrooke.com
Whitney.Cruz@bowmanandbrooke.com
Attorneys for Defendant, Tesla, Inc. d/b/a Tesla Florida, Inc. and Halston Loyd


LAURIE A. PRIMUS, ESQ.
SELLARS, MARION & BACHI, P.A.
811 North Olive Avenue
West Palm Beach, FL
Telephone: (561) 655-
Facsimile: (561) 655-
Service email: pleadings@smb-law.com
Attorneys for Defendants, James B. Riley and JR Corporate Services Group, LLC
Page 4 IN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA
CASE NO.: CACE-19-EDGAR MONSERRATT, as_ Personal
Representative of THE ESTATE OF
EDGAR MONSERRATT MARTINEZ,
Deceased,
Plaintiff,
V.
TESLA, INC. a/k/a TESLA FLORIDA,
INC., HALSTON LOYD, JAMES BB.
RILEY, individually, JAMES B. RILEY as
the Personal Representative of THE
ESTATE OF BARRETT RILEY, Deceased,
and JR CORPORATE SERVICES GROUP
LLC, a Florida limited liability company,
Defendants.
/

SUBPOENA DUCES TECUM (MAIL IN ONLY)
TO: NBC 6 South Florida
15000 SW 27 Street
Miramar FL
YOU ARE COMMANDED TO appear at the law offices of Schlesinger Law Offices,
P.A., 1212 SE Third Ave., Ft. Lauderdale, FL 33316 within TEN DAYS of the date of service
of this subpoena*, and to have with you the following documents and materials:
1. Full, unedited and complete copies of any and all photographs, video recordings,
and/or broadcast tapes related to the crash of a Tesla Motor vehicle (operated by Barrett
Riley) on Seabreeze Boulevard in Fort Lauderdale, FL on May 8, 2018, aired and/or
reported on May 8, 2018 and thereafter.
2. Full, unedited and complete copies of any and all photographs, video recordings,
and/or broadcast tapes depicting the scene of the crash of a Tesla Motor vehicle (operated
by Barrett Riley) on Seabreeze Boulevard in Fort Lauderdale, FL on May 8, 2018, aired
and/or reported on May 8, 2018 and thereafter.
3. Full, unedited and complete copies of any and all photographs, video recordings,
and/or broadcast tapes depicting the damages to the Tesla Motor vehicle (operated by
Barrett Riley) which crashed on Seabreeze Boulevard in Fort Lauderdale, FL on May 8,
2018, aired and/or reported on May 8, 2018 and thereafter.
Page 5 4. Full, unedited and complete copies of any and all photographs, video recordings,
and/or broadcast tapes depicting the occupants of a Tesla Motor vehicle (operated by
Barrett Riley) which crashed on Seabreeze Boulevard in Fort Lauderdale, FL on May 8,
2018, aired and/or reported on May 8, 2018 and thereafter.
YOUR RESPONSE IS DUE BY:
10 DAYS FROM THE DATE OF SERVICE OF THIS SUBPOENA
*You may mail or deliver copies to the attorney whose name appears on this
subpoena and thereby eliminate your appearance at the time and place
specified above.
These items will be inspected and may be copies at that time. You will not be required to
surrender the original items. You may comply with this subpoena by providing legible copies of
the items to be produced to the attorney whose name appears on this subpoena on or before the
scheduled date of production. You may condition preparation of the copies upon the payment in
advance of the reasonable cost of preparation. You have the right to object to the production
pursuant to this subpoena at any time before the production by giving written notice to the attorney
whose name appears on this subpoena.
THIS WILL NOT BE A DEPOSITION, NO TESTIMONY WILL BE TAKEN.
If you fail to: (1) Appear as specified, or
(2) furnish the records instead of appearing as provided above, or
(3) object to this subpoena;
You may be in contempt of court. You are subpoenaed by the attorney whose name
appears on this subpoena and unless excused from this subpoena by the attorney or the Court,
you shall respond to this subpoena as directed.
DATED this day June, 2019.
SCHLESINGER LAW OFFICES, P.A.
Attorneys for Plaintiffs
1212 SE Third Avenue
Fort Lauderdale, Florida
/s/ Zane Ber
Scott P. Schlesinger, Esq.
Florida Bar No.: scott@schlesingerlaw.com
Jonathan R. Gdanski, Esq.
Florida Bar No.: jonathan@schlesingerlaw.com
Zane Berg, Esq.
Florida Bar No.: zane@schlesingerlaw.com
Page 6 IN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA
CASE NO.: CACE-19-
EDGAR MONSERRATT, as_ Personal
Representative of THE ESTATE OF
EDGAR MONSERRATT MARTINEZ,
Deceased,
V.
Plaintiff,
TESLA, INC. a/k/a TESLA FLORIDA,
INC., HALSTON LOYD, JAMES BB.
RILEY, individually, JAMES B. RILEY as
the
Personal Representative of THE
ESTATE OF BARRETT RILEY, Deceased,
and JR CORPORATE SERVICES GROUP
LLC, a Florida limited liability company,


Defendants.
/
SUBPOENA DUCES TECUM (MAIL IN ONLY)
TO: CBS 4 Miami
8900 SW 18 Terrace
Doral FL
YOU ARE COMMANDED TO appear at the law offices of Schlesinger Law Offices,
P.A., 1212 SE Third Ave., Ft. Lauderdale, FL 33316 within TEN DAYS of the date of service
of this subpoena”, and to have with you the following documents and materials:
1. Full, unedited and complete copies of any and all photographs, video recordings,
and/or broadcast tapes related to the crash of a Tesla Motor vehicle (operated by Barrett
Riley) on Seabreeze Boulevard in Fort Lauderdale, FL on May 8, 2018, aired and/or
reported on May 8, 2018 and thereafter.
2. Full, unedited and complete copies of any and all photographs, video recordings,
and/or broadcast tapes depicting the scene of the crash of a Tesla Motor vehicle (operated
by Barrett Riley) on Seabreeze Boulevard in Fort Lauderdale, FL on May 8, 2018, aired
and/or reported on May 8, 2018 and thereafter.
3. Full, unedited and complete copies of any and all photographs, video recordings,
and/or broadcast tapes depicting the damages to the Tesla Motor vehicle (operated by
Barrett Riley) which crashed on Seabreeze Boulevard in Fort Lauderdale, FL on May 8,
2018, aired and/or reported on May 8, 2018 and thereafter.
Page 7 4. Full, unedited and complete copies of any and all photographs, video recordings,
and/or broadcast tapes depicting the occupants of a Tesla Motor vehicle (operated by
Barrett Riley) which crashed on Seabreeze Boulevard in Fort Lauderdale, FL on May 8,
2018, aired and/or reported on May 8, 2018 and thereafter.
YOUR RESPONSE IS DUE BY:
10 DAYS FROM THE DATE OF SERVICE OF THIS SUBPOENA
*You may mail or deliver copies to the attorney whose name appears on this
subpoena and thereby eliminate your appearance at the time and place
specified above.
These items will be inspected and may be copies at that time. You will not be required to
surrender the original items. You may comply with this subpoena by providing legible copies of
the items to be produced to the attorney whose name appears on this subpoena on or before the
scheduled date of production. You may condition preparation of the copies upon the payment in
advance of the reasonable cost of preparation. You have the right to object to the production
pursuant to this subpoena at any time before the production by giving written notice to the attorney
whose name appears on this subpoena.
THIS WILL NOT BE A DEPOSITION, NO TESTIMONY WILL BE TAKEN.
If you fail to: (1) Appear as specified, or
(2) furnish the records instead of appearing as provided above, or
(3) object to this subpoena;
You may be in contempt of court. You are subpoenaed by the attorney whose name
appears on this subpoena and unless excused from this subpoena by the attorney or the Court,
you shall respond to this subpoena as directed.
DATED this day of June, 2019.
SCHLESINGER LAW OFFICES, P.A.
Attorneys for Plaintiffs
1212 SE Third Avenue
Fort Lauderdale, Florida
/s/ Zane Ber
Scott P. Schlesinger, Esq.
Florida Bar No.: scott@schlesingerlaw.com
Jonathan R. Gdanski, Esq.
Florida Bar No.: jonathan@schlesingerlaw.com
Zane Berg, Esq.
Florida Bar No.: zane@schlesingerlaw.com
Space
Issues Laws Cases Pro Articles Firms Entities
Issues Laws Cases Pro Articles Firms Entities
 
PlainSite
Sign Up
Need Password Help?